Good faith transitional relief under FATCA provided by US Treasury and IRS
On May 2, 2014, the US Treasury Department (Treasury) and Internal Revenue Service (IRS) announced in Notice 2014-33 (the Notice) that calendar years 2014 and 2015 will be regarded as a transition period for IRS enforcement and administration purposes with respect to the implementation of the Foreign Account Tax Compliance Act (FATCA or Chapter 4).
EU FTT
EU FTT: UK’s challenge blocked for now but UK Treasury indicates they will not let it be. In april 2013, the UK launched a legal challenge against the introduction of an EU Financial Transaction Tax (‘EU FTT’) under the Enhanced Cooperation Procedure (‘ECP’). Two days before, the Court of Justice of the European Union (‘CJEU’) released
ECOFIN fails to reach agreement on anti-hybrid measure to be implemented into the Parent-Subsidiary Directive – FTT first on shares and some derivatives
1. Background On 25 November 2013, the European Commission has proposed to amend the EU Parent-Subsidiary Directive (‘PSD’) in order to tackle tax fraud/evasion and aggressive tax planning/base erosion and profit shifting (‘BEPS’) within the European Union. The proposal sought to insert (i) a specific anti-abuse rule for hybrid loan arrangements resulting in a double
Belgium and the US sign FATCA Intergovernmental Agreement
On 23 April 2014, Minister of Finance, Koen Geens and US Ambassador, Mark Storella signed the long awaited bilateral Intergovernmental Agreement (IGA) intended to implement the Foreign Account Tax Compliance Act (FATCA). The IGA will provide needed clarity around the implementation of FATCA for the Financial Institutions (FIs) resident in Belgium and those with branches
EC Infringement Procedure
On 16 April the European Commission requested the Netherlands to end the discriminatory tax charge on dividends received on shares held by insurance companies based in another EU Member State or EEA member country
FATCA Intergovernmental Agreement between Belgium and US will be signed on 23 April
On 12 April 2014, the Minister of Finance Koen Geens has announced the imminent signing of the agreement between the United States and Belgium regarding the mutual exchange of financial information and the implementation of FATCA (Foreign Account Tax Compliance Act). The technical negotiations have been concluded and the agreement is finalised. The Minister of
New tax on parking spaces in the Brussels Region
A new (environmental) tax on parking spaces will be effective as from 1 January 2015 (in accordance with the order of 2 May 2013 of the Brussels Region that entered into force on 5 February 2014). The tax is mainly applicable to owners of office buildings. The order limits the amount of parking spaces according
The IRS announced yesterday that it will treat 19 countries as having IGAs in effect.
On 2 April 2014, the US Treasury Department (Treasury) and the Internal Revenue Service (IRS) announced that jurisdictions that have reached agreements in substance with the United States on the terms of intergovernmental agreements (IGAs) under the Foreign Account Tax Compliance Act (FATCA) can be treated as having agreements in effect until the end of
